RS-05-076, Clarification of Regulatory Commitments Related to Extended Power Uprate (EPU) Operation
| ML051650054 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 06/13/2005 |
| From: | Simpson P Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-05-076 | |
| Download: ML051650054 (2) | |
Text
'June 13, 2005 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 Subject :
Clarification of Regulatory Commitments Related to Extended Power Uprate (EPU) Operation References :
1.
Letter from J. A. Benjamin (Exelon Generation Company, LLC) to U. S. NRC, "Commitments and Plans Related to Extended Power Uprate Operation,"
dated May 13, 2005 2. TIC-1239, "Quad Cities Unit 2 Power Ascension Test Procedure for the Reactor Vessel Steam Dryer Replacement," Revision 0 In Reference 1, Exelon Generation Company, LLC (EGC) made several commitments regarding the operation of Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS), Ms 1 and 2, including commitments to provide the NRC with periodic updates and feedback on steam dryer data and the assessment of steam dryer loads during power ascension testing of the QCNPS units. Due to changes in the startup test plan schedules for both QCNPS units, and potential schedule impacts of planned teleconferences on plant operations and testing, EGC revised its original schedule for conducting some of the technical updates with the NRC. In addition, the NRC provided feedback that comparisons of the results with scale model testing were not specifically emphasized during all of the briefings.
EGC subsequently outlined the manner in which the intent of the commitments were being met, and agreed to provide the NRC with a clarification of the commitments impacted by the revised startup testing schedule. This letter addresses the applicable commitments.
Commitment 9 of Reference 1 states, "As a minimum, EGC will provide feedback to the NRC on the steam dryer data and other plant instrumentation data and the assessment of the design-basis load cases (i.e., including the acoustic circuit and scale models) during the 24-hour hold point at 2511 [megawatts thermal] MWt... " This commitment is related to the operation and testing of the instrumented QCNPS Unit 2 replacement steam dryer. During the startup test
June 13, 2005 U. S. Nuclear Regulatory Commission Page 2 program, instrumentation reading trends on the replacement dryer indicated that acceptance criteria would be exceeded above 2511 MWt. Therefore, QCNPS Unit 2 entered a 24-hour hold point at 2493 MWt, as opposed to 2511 MWt as stated in Commitment 9. To address this discrepancy, Test Conditions 32 and 33 were consolidated in Reference 2 while detailed evaluations were conducted to support continued startup testing above 2511 MWt. Therefore, the briefing with the NRC occurred Q 2493 Ace 2511 MWt. The change in the hold point had no impact on the type of information available to share with the NRC.
In addition, Commitment 9 states that EGC will provided feedback on steam dryer data and other plant instrumentation data and the assessment of the design-basis load cases "after 14 days of EPU operation" on QCNPS Unit 2. In developing this commitment EGC established 14 days as a reasonable time for completing evaluation of collected data on this unit. The evaluations were completed prior to 14 days of EPU operation, and EGC included feedback on the results of the evaluations during a technical update teleconference on Wednesday, June 1, 2005, approximately 10 days after commencing EPU operation. Since no additional information or insights related to these evaluations were gained during the interim between 10 and 14 days of EPU operation, EGC considered the intent of the commitment to be met.
Commitment 9 further states, "Specific acceptance criteria for the design-basis load cases, including the acoustic circuit and scale models, shall be prepared prior to initiating the assessment of the load cases." Acceptance criteria for the acoustic circuit model and small scale model were referenced in Reference 2. To support the technical debriefings held on May 20, May 23, and June 1, 2005, EGC provided data packages containing comparisons of QCNPS Unit 2 steam dryer loads to acceptance criteria based on the design load cases (acoustic circuit and small scale models). Therefore, EGC considers the commitment to be met. As outlined in Commitments 9 and 10 of Reference 1, detailed results and comparisons of in-plant data to analytical and scale modeling will be submitted to the NRC.
Should you have any questions concerning this letter, please contact Mr. Thomas G. Roddey at (630) 657-2811.
Respectfully, Patrick R. Simpson Manager-Licensing